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Kidder v. C.I.R.

United States Court of Appeals, Ninth Circuit
Feb 23, 2001
4 F. App'x 515 (9th Cir. 2001)

Opinion


4 Fed.Appx. 515 (9th Cir. 2001) Warren Jack KIDDER; Barbara Jeanne Kidder, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Tax Court No. 24216-97. No. 00-70444. United States Court of Appeals, Ninth Circuit. February 23, 2001

Submitted February 12, 2001.

The panel unanimously finds this case suitable for decision without oral argument. See Fed. R.App. P. 34(a)(2).

NOT FOR PUBLICATION. (See Federal Rule of Appellate Procedure Rule 36-3)

Taxpayers sought review of federal income tax determination by Commissioner of Internal Revenue (CIR). The United States Tax Court upheld determination. Taxpayers appealed. The Court of Appeals held that taxpayers had failed to show the existence of a valid debt owed to them, for purposes of bad debt deduction.

Affirmed.

Page 516.

Appeal from the United States Tax Court.

Before LEAVY, THOMAS, and RAWLINSON, Circuit Judges.

MEMORANDUM

This disposition is not appropriate for publication and may not be cited to or by the courts of this circuit except as may be provided by 9th Cir. R. 36-3.

Warren Jack Kidder and Barbara Jeanne Kidder appeal pro se from the tax court's decision upholding the Commissioner of the Internal Revenue's federal income tax determination for the tax years 1992 and 1993. We have jurisdiction pursuant to 26 U.S.C. § 7482. We review de novo the tax court's conclusions of law and for clear error its findings of fact, see Kelley v. Commissioner, 45 F.3d 348, 350 (9th Cir.1995), and affirm.

The tax court did not err in determining that the Kidders failed to establish that a valid debt existed between them and Mr. Bogue for purposes of the bad debt deduction under 26 U.S.C. § 166. See Zimmerman v. United States, 318 F.2d 611, 613 (9th Cir.1963).

AFFIRMED.


Summaries of

Kidder v. C.I.R.

United States Court of Appeals, Ninth Circuit
Feb 23, 2001
4 F. App'x 515 (9th Cir. 2001)
Case details for

Kidder v. C.I.R.

Case Details

Full title:Warren Jack KIDDER; Barbara Jeanne Kidder, Petitioners-Appellants, v…

Court:United States Court of Appeals, Ninth Circuit

Date published: Feb 23, 2001

Citations

4 F. App'x 515 (9th Cir. 2001)